Platform Privacy Policy (full)

Privacy Policy

Platform
(Version of January 2022)

This Privacy Policy, hereinafter the Policy, is intended to inform the users of the ALCMEON application (hereinafter the “Users” and the “Application”), on the manner and the purposes, for which ALCMEON collects, uses and discloses their personal data.

Personal data (the “Data”) means any information relating to an identified or identifiable natural person.

“Users” of the Application are the clients of ALCMEON as well as their employees, clerks or their sub-contractors.

ALCMEON grants a particular importance to the protection of data that Users entrust and undertakes to respect the privacy of the Users.

This Policy is designed to comply with the requirements of the applicable privacy laws, including 

Article 1. Acceptance of the Policy

The Policy is an integral part of our General Conditions of Use and applies to Users of our Application.

The acceptance of all these documents by the User is necessary for the use of the Application, as they formalise the contractual link between ALCMEON and the User.

If a user is opposed to any of the provisions of this Policy, they remain free to stop the use of the application. 

ALCMEON reserves the right to amend and supplement this Policy at any time. The version currently in force is the one available in the Application at the date of the connection of the User to the Application.

It is agreed that the invalidity of a contractual clause does not entail the nullity of the whole Policy.

Article 2. Processing of Personal Data

All data provided by the user to ALCMEON is treated with the utmost confidentiality. 

2.1. Nature of the Data collected

During the creation of your user account, ALCMEON collects the email address of the User.

This Data is essential for the creation of a user account in the ALCMEON application.

In the framework of the functioning of the Application, ALCMEON may also be brought to process on behalf of Users the Data which could be communicated by your customers (hereinafter referred to as “Consumers”), in particular in order to provide you with the evaluations and statistics and more generally, in order to ensure the operation of the Application.

The service offered by ALCMEON consists in particular in managing requests made by the Consumers on social networks, such as Facebook, Instagram and Twitter, and instant messaging applications, such as WhatsApp, Apple Messages and Google Business Messages. The access to these platforms requires User’s acceptance of their policies relating to the protection of personal data, which are totally independent from that of the Application.

The service offered by ALCMEON allows Users of its Application to authorise social networks, such as Facebook, Instagram and Twitter, instant messaging applications, such as WhatsApp, Apple Messages and Google Business Messages, and inMessage, an asynchronous chat widget operated by ALCMEON, to transmit to ALCMEON certain information relating to messages sent by Consumers on the account that the Users have on these platforms.

The information transmitted in this framework to ALCMEON are the following: 

– Identification data of the Customers: on the one hand, data provided by social networks and instant messaging applications on Customers such as their identifier (first and last name, pseudonym, or telephone number) and profile photo; on the other hand, data provided by Customers on their own initiative in the context of their exchanges with Users on social networks, instant messaging applications, and ALCMEON’s asynchronous chat widget, such as email address, telephone number, customer number, order number, etc. Except under specific agreement between Alcméon and the Client, these data do not include any special categories as defined by the GDPR.

– Messages exchanged between the Users and their Customers, including text and attachments (photos, animated gifs, videos, pdf documents), published with time stamp, received from the Customers and sent by the Users, and in some cases declarative location received from the Customers through the concerned social network or messaging application.

ALCMEON will act in this framework as a sub-contractor and by application of the applicable regulations, is committed in particular to:

In all cases, we limit ourselves to collecting and processing data that is adequate, not excessive and strictly necessary for the fulfilment of the purposes that have been determined in advance. 

2.2. Minors

ALCMEON does not voluntarily collect data from minors under the age of 15 years, but some information can be retrieved automatically. In that case such data is processed according to this Policy.

Once identified as coming from children below the age of 15 years, ALCMEON undertakes to delete this data as soon as possible.

2.3. Purposes of processing and duration of data storage

The data of Users collected by ALCMEON is used for: 

The Consumer data is processed to allow ALCMEON to provide its services by putting at the User’s disposal:

The data collected is for internal use within ALCMEON and strictly limited to the most appropriate teams. 

The Company keeps your Data only for the duration necessary for the purposes described above. 

The Company keeps the data relating to your User account until you delete your account.

Beyond this duration, the data may be made anonymous and kept exclusively for statistical purposes and will not give rise to any use of any nature whatsoever.

The operations described here above do not serve for creation of profiles likely to contain so-called sensitive Personal Data say such as the racial or ethnic origin, philosophical, political, labour-related or religious opinions, sexual life or health.

2.4. Legal basis of the processing

If you create an account in ALCMEON, the data collected is necessary to provide our services to you and provide all the assistance you need.

We may also collect personal data for purposes of legitimate interest such as the improvement of our services. You can oppose the processing of your data on this basis at any time.

In certain circumstances, and particularly when the legal bases mentioned above are not applicable, we are required to obtain your express consent to the processing of your data. In this case, you may withdraw your consent at any time.

2.5. Information shared with third parties

The processing of the personal data collected is strictly confidential.

ALCMEON does not transmit any personal data to a third party likely to use it for their own purposes, in particular for a commercial or advertising use, without having requested the prior consent of the User.

It is possible that ALCMEON may transfer certain personal data to third-party partners in a temporary way and secure way to ensure the proper execution of the services it offers. 

In this context, the partners concerned can be brought to have access to User’s personal data and process it for the account of ALCMEON, according to the instructions of the latter and in compliance with this Policy, as well as of any appropriate security and confidentiality measures.

When these partners are located outside of the European Union or in a country that does not have regulations adequate for the requirements of the applicable laws governing the respect of privacy, particularly to the General Regulation on the Protection of Data and French laws transposing it, ALCMEON oversees its contractual relationship with this partner, adopting an appropriate contractual device . 

2.6. Hosting of data

The collected data is stored on secure servers located in France or in another Member State of the European Union.

It is possible that ALCMEON may have the data collected through its servers transferred to those of its partners present in countries, whose legislation provides a level of protection of data that may be different from that of the European Union.

In this hypothesis, ALCMEON will take all the necessary measures in order to maintain a level of security of the data collected at least equal to the level required by the European regulations on the personal data. 

Article 3. Rights of Users

3.1. Nature of the rights of Users

In accordance with the laws relating to the protection of personal data in force, in particular to the General Regulation on the Protection of Data and French laws transposing it, all Users have the following rights:

In addition, the User is informed that they may withdraw their consent to the processing of their personal data at any time. 

3.2. Exercise of the rights of Users

At any time, the user may exercise their rights by sending their request, indicating their last name, first name, postal and e-mail address and a copy of both sides of their identity card, either:

Data Protection Officer

ALCMEON – Mr. Mathieu LACAGE
Bâtiment Taissounières B2
1681 route des Dolines
06560 Valbonne Sophia Antipolis

A response will be provided within a period of one month from the receipt of the request.

The User can also at any time ask ALCMEON to no longer receive advertisements or prospecting adapted to the navigation information from their terminal, by contacting ALCMEON directly and free of charge by the means mentioned above or using the unsubscribe link included in any prospecting that ALCMEON might send to them by electronic mail. 

The User, acting through a person previously empowered to make such a request, may also transmit to ALCMEON the request of a Consumer at any time by performing the same steps, after having verified that the applicant is indeed the person whose data has been processed.

The User shall specify:

– The identifier of the Consumer on the social network concerned

– The nature of the requested operation

Finally, the User can file a complaint with the competent authority, namely the CNIL for the French territory.

Article 4. Use of Cookies

The User is informed that a cookie may be automatically installed in their browsing software at the time of their visits of the Application, . A cookie is a file, often anonymous, containing data, including a unique identifier, transmitted by the server of the Application to the User’s browser and stored on their hard disk.

During each visit of the Application by a User, these cookies allow carrying out comprehensive statistical studies on the audience of the Application, to identify the User where appropriate, to investigate the behaviour of Users within the different areas of the Application, in order to customise the Site as much as possible in terms of organisation, display and content in function of the personal data collected from the User.

The User has the possibility to oppose the saving of cookies by configuring their browser.

The cookies placed in the Application are the following:

Type of cookieSourceUseExpiry date
Cookie for authentication Alcméon applicationThese cookies are used to identify the visitors of our service and control their access to our service. For obvious security reasons, a User who has disabled this cookie and therefore cannot be identified cannot have access to our Application.Session: A session is terminated when the client browser is closed.
Cookie allowing the analysis of traffic:

ga, gat and gid

Google AnalyticsThese cookies are used to collect information on how visitors use our service. We use this information to compile reports and help us improve the site. Cookies collect information in an anonymous form, including the number of visitors on the site, how the visitors came to the site and which pages they have visited.Some of these cookies are automatically deleted from your system when you close your browser.

Other cookies may remain for a period of up to 13 months from the date of your last visit on our site.

You can choose not to be analysed by Google Analytics by visiting the following page: https://tools.google.com/dlpage/gaoptout?hl=fr.

 

The configuration of these settings is different depending on the browser used. The method to follow is specified in the Help menu of the User’s browser. 

However, the User is informed that the access to some services of the Application may be impossible or altered where appropriate.

Cookies from third-party sites can be saved on the User’s terminal during the browsing of the Application. These cookies may in particular originate from the content from social networks published in the Application or the use of the Flash application to view animations graphics or video sequences.

During browsing of the ALCMEON pages on social networks, cookies from these social networks or third-party sites may be installed in the User’s browser. These cookies are subject to the privacy protection policies of these third-party sites and are beyond control of ALCMEON.

The user is invited to take knowledge of the policy for the management of the cookies of social networks and Flash cookies by going on the sites concerned.

The duration of storage of the cookies is 13 months.

Article 5. Applicable law – Competent Jurisdiction

The present general conditions of use are governed by the French law.

In the event of a dispute concerning in particular the validity, interpretation and/or execution of the present conditions, the French courts will be competent regardless of the location and the nationality of the User.